CELEBREZZE, J.
The issue before the court, as it was before the Tax Commissioner and the Board of Tax Appeals, concerns construction of the "business done" apportionment formula contained in R. C. 5733.05 as it applied to tax years 1970 and 1971.
At that time, R. C. 5733.05 provided, in pertinent part:
"* * * take the other part and multiply by a fraction whose numerator is the value of the business done, measured by sales of tangible personal property...
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